1 min read

How HIPAA applies to hybrid entities

Liyanda Tembani December 04, 2023

HIPAA center

HIPAA mandates strict compliance for the covered segments of hybrid entities, including designated officials, policies, and PHI protection. Non-covered parts support privacy measures for PHI from covered segments, fostering an organization-wide security culture.

What are hybrid entities?

Hybrid entities represent organizations that house both HIPAA covered and non-covered components. Covered components encompass entities like healthcare providers, health plans, or healthcare clearinghouses that handle PHI and are thus subjected to HIPAA's Privacy Rule requirements. Conversely, non-covered segments within these organizations aren't directly bound by HIPAA's compliance obligations but play a role in maintaining the integrity of PHI shared from covered components.

HIPAA's impact on hybrid entities

HIPAA's Privacy Rule significantly influences hybrid entities, shaping their compliance landscape. Covered components must adhere to stringent obligations outlined by HIPAA. These obligations range from appointing a designated privacy official responsible for overseeing HIPAA compliance across the entire organization to crafting comprehensive policies and procedures, providing workforce training on HIPAA compliance, and ensuring the safeguarding of PHI handled within covered entity components.

Related: What is a covered entity?

How to designate covered and non-covered components

Identifying covered entity components within hybrid entities requires a meticulous identification process. This process must be carried out with great care and attention to detail. These components, once identified, must comply with HIPAA's requirements. Non-covered entity segments, while not directly subjected to HIPAA obligations, are integral to the organization's privacy ecosystem. They often implement measures to prevent unauthorized access or disclosure of PHI from covered components, fostering a culture of privacy and security throughout the organization.

The HIPAA compliance requirements for covered components

Establishing and implementing policies and procedures that align with HIPAA's stringent guidelines,
Ensuring comprehensive workforce training on HIPAA compliance,
Securing PHI through robust technological and procedural measures,
and diligently adhering to strict privacy protocols mandated by HIPAA.

Flexibility and data sharing within hybrid entities

Hybrid entities have flexibility in managing PHI among their covered entity components. HIPAA's framework allows for certain data-sharing practices within the boundaries of compliance, facilitating a smoother exchange of health information among segments while upholding stringent privacy standards.